1 

### Wisconsin Area Designations for the

20 08 Ozone National Ambient Air Q uality Standard s

The t able below identifies the areas and associated counties or parts of counties in Wisconsin that EPA

is designating as no n attain ment for the 2008 o zone national amb ient air quality standard s (20 08 NAAQS) . In accordance with section 107(d) of the Clean Air Act, EPA must designate an area (county or part of a county) “nonattainment” if it is violating the 2008 ozone NAAQS or if it is contributing to a

violation of the 2008 ozone NAAQS in a nearby area. The technical analyses supporting the boundaries

for th is nonattainment area are provided below.

Table 1: Nonattainment Areas in Wisconsin

Area Wisconsin’s Recommended

Nonattainment Counties EPA’s Nonattainment Coun ties

Sheboygan, WI None Sheboygan County

EPA is designat ing the remaining counties and areas of Indian country in Wisconsin that are not listed in

the table above or being considered for inclu sion as part of the Chicago

- Naperville, IL

- IN

- WI ozone

nonatt ainment area as “ unclassifiable/ attainment ” for the 2008 ozone NAAQS. EPA will issue no later than May 31, 2012 one or more designations for the areas being considered as part of the Chicago

Naperville, IL

- IN

- WI ozone nonattainment area and will prepare a separate technical support document

for that action. EPA received designation recommendations from the Forest County Potawatomi Community and the Oneida Tribe of Indians of Wisconsin. EPA is concurring with the recommendations submitted by both tribes t hat that their areas of Indian country be designated as unclassifiable/attainment along with the surrounding state areas.

The analysis below provides the basis for the nonattainment area boundar ies for the Sheboygan, WI

nonattainment area . It relies on our analysis of whether and which monitors are violating the 20 08

o zone NAAQS

, based on certified air quality monitoring data from 2008

- 2010 and an evaluation of whether nearby areas are contributing to such violations. EPA has evaluated contributions from the surrounding counties based on a weight of evidence analysis considering the factors identified below. EPA issued guidance on December 4, 2008

, that identified these factors as ones EPA would consider in determining nonattainment area boundaries a nd recommend ed that s tates consider these factors in making their designations recommendations to EPA. 1

1. Air quality data ( including the design value calculated for each Federal Reference Method (FRM) or Federal Equivalent Method (FEM) monitor in the ar ea );

2. Emissions and emissions

- related data (including location of sources and population , amount of

emissions and emissions controls , and urban growth patterns);

3. Meteorology (weather/transport patterns) ; 4. Geography and topography (mountain ranges or other ba sin boundaries) ; 5. Jurisdictional boundaries (e.g., counties, air districts, existing nonattainment areas, Indian

country , metropolitan planning organizations (MPOs))

1 The December 4, 2008 guidance memorandum “Area Designations for the 2008 Revised Ozone National Ambient Air Quality Standards” refers to 9 factors. In this technical support document we have grouped the emissions

- related factor s together under the heading of “Emissions and Emissions

- Related Data

, ” which results in 5 categories of factors.2 Ground

- level ozone is generally not emitted directly into the air, but is created by chemi cal reactions between oxides of nitrogen (NOx) and volatile organic compounds (VOC) in the presence of sunlight.

Because NOx and VOC emissions from a broad range of sources over a wide area typically contribute to

violations of the ozone standard s , EPA be lieves it is important to consider whether there are contributing emissions from a broad geographic area. Accordingly, in general

, EPA chose to examine the 5 factors with respect to the larger of the Combined Statistical Area (CSA) or Core Based Statistica l Area (CBSA) associated with the violating monitor(s)

. 2 However, since the Sheboygan, WI Metropolitan Statistical Area ( MSA ) consists of a single county, EPA also chose to evaluate the counties immediately adjacent to Sheboygan County. All data and info rmation used by EPA in this evaluation are the latest available to EPA and/or provided to EPA by states or tribes.

In EPA’s designations guidance for the 2008 ozone NAAQS 3 EPA recommended examining

CSA/CBSA s because certain factors used to establish CSAs and CBSAs are similar to the factors EPA is using in this technical analysis to determine if a nearby area is contributing to a violation of the 20 08 ozone NAAQS. Congress required a similar approach in 1990 for areas classified as serious or above

for th e 1

- hour ozone standard and EPA used the same basic approach in the designation process for the

1997 o zone NAAQS. Where a violating monitor is not located in a CSA or C BS A, EPA ’s guidance recommended using the boundary of the county containing the violati ng monitor as the starting point for considering the nonattainment area’s boundary.

Technical A nalysis for Sheboygan, WI

The largest statistical area associated with Sheboygan County , WI is the Sheboygan, WI MSA. Th e Sheboygan, WI MSA consists of the single county of Sheboygan. Figure 1 is a map of the Sheboygan,

WI nonattainment area . The map provides other relevant information including the locations and design values of air quality monitors , county and other jurisdictional boundaries, Sheboygan M SA boundary

, existing nonattainment boundary for the 1997 ozone NAAQS, and major transportation arteries.

2 Lists of CBSAs and CSAs and their geographic components are provided at www.census.gov/population/www/metroareas/metrodef.html . The lists are periodically updated by the Office of Management and Budget. EPA used the most recent update, based on 2008 population estimates, issued on December 1, 2009 (OMB Bulletin No . 10

- 02).

3 See Appendix [x] for a copy of the guidance memorandum.3 Figure 1.

For purposes of the 1997 8

- hour ozone NAAQS, this area was designated nonattainment. The boundary

for the nonattainment area for the 19 97 o zone NAAQS included the entire county of Sheboygan.

In March 2009

, Wisconsin recommended that all counties in the state be designated as “ attainment ” for

the 2008 ozone NAAQS based on air quality data from 2006

- 2008

. 4 It should be noted that 2006

- 20 08 monitoring data showed a violation of the 2008 ozone NAAQS in Sheboygan County. These data are

from a monitor sited and operated in accordance with 40 CFR Part 58

.

After considering these recommendations and b ased on EPA's technical analysis describ ed below, for the Sheboygan, WI nonattainment area, EPA is designat ing Sheboygan County ( see Table 1 above ) as

“ nonattainment ” for the 20 08 o zone NAAQS

.

Factor Assessment

4 Wisconsin supplied its designation recommendations in a March 12, 2009 letter from Governor Jim Doyle. The state also provided a Technical Support Document dated February 27, 2009, whic h included a nine factor analysis to support the

Governor’s recommendation decisions.4 

### Factor 1: Air Quality Data

For this factor , we considered 8

- hour o zone design values (in ppm) for air quality monitors in the Sheboygan, WI area and immediately adjacent counties based on data for the 2008

- 2010 period, which

are the most recent years with fully

- certified air quality data

. A monitor’s design value is the metric or

statistic that indicates whether that monitor attains a specified air quality standard. The 2008 o zone NAAQS are met at a monitor when the annual f ourth

- highest daily maximum 8

- hour average concentration, averaged over 3 years is 0.075 ppm or less

. A des ign value is only valid if minimum data completeness criteria are met. See 40 CFR part 50 App endix P . Where several monitors are located in a county (or a designated nonattainment area or maintenance area ), the design value for the county or area

is dete rmined by the monitor with the highest individual design value

.

Note: Monitors that are eligible for providing design value data generally include State and Local Air Monitoring Stations (SLAMS) that are sited in accordance with 40 CFR Part 58, Appendix D (Section 4.1) and operating with a federal reference method (FRM) or federal equivalent method (FEM) monitor that meets the requirements of 40 CFR part 58, appendix A. All data from a special purpose monitor (SPM) using an FRM or FEM which has operated for more than 24 months is eligible for comparison to the NAAQS unless the monitoring agency demonstrates that the data came from a particular period during which the requirements of appendix A (quality assurance requirements) or appendix E (probe and

mon itoring path siting criteria) were not met.

The 2010 design value for the Sheboygan, WI MSA is shown in Table 2

.

Table 2 . Air Quality Data

.

County State Recommended

Nonattainment? 2008

- 2010 Design Value ( ppb )

Sheboygan County No 78

Calumet County No

Fond du Lac County No 63

Manitowoc County No 73

Ozaukee County No 71

Washington County No

Sheboygan County shows a violation of the 2008 o zone NAAQS , t herefore this county is included in the

nonattainment area

. Although none of the counties adj acent to Sheboygan County are monitoring a

violation of the 2008 8

- hour ozone NAAQS, each of these counties ha s been evaluated , as discussed below, based on the five factors to determine whether it contributes to the violation

.



### Factor 2: Emissions and E missions

- Related Data

EPA evaluated emissions of ozone precursors ( NO x and VOC ) and other emissions

- related data that provide information on areas contributing to violating monitors.5 Emissions Data

EPA evaluated county

- level emission data for NO x and V OC derived from the 200 8 National Emissions Inventory (NEI), version 1.5

. This is the most recently available NEI. (See http://www.epa.gov/ttn/chief/net/2008inventory.html

. ) Significant emissions levels in a nearby area indicate the potential for the area to contribute to the observed ozone standard violation. Table 3 shows

2008 emissions of NO x and VOC (in tons per year) for the Sheboygan, WI MSA (Sheboygan County) and all adjacent coun ties . This table also indicates which of the counties were recommended to be nonattainment for the 2008 ozone NAAQS by Wisconsin.

Table 3 shows 2008 emissions of NO x and VOC (in tons per year) for the Sheboygan, WI MSA and the adjacent counties

.

Table 3

. Total 2008 NO x and VOC Emissions.

County State Recommended

Nonattainment ? NO x (tpy) VOC (tpy)

Sheboygan C ounty No 7,885 6,291 Calumet County No 1,287 2,323 Fond du Lac County No 3,810 5,066 Manitowoc County No 3,668 4,626 Ozaukee County No 3,690 3,375 Washington County No 3,977 6,675

Sheboygan County must be included in the nonattainment area because of the monitored violation of the NAAQS within the county

. Sheboygan County has the highest level of emissions of the counties;

h owever, Sheboyg an and the adjacent counties all have relatively low emissions. T he low emission

levels in the area indicate that longer range transport is the significant contributor to violations of the standard in the Sheboygan, WI area. This conclusion is supported by m odeling performed for the Cross

State Air Pollution Rule which shows the states of Illinois, Indiana, Wisconsin and Michigan contributing 28.209 ppb, 11.244 ppb

, 8.437 ppb , and 3.117 ppb , respectively, to ozone concentrations at the Sheboygan County m onitoring site

.

Population D ensity and D egree of U rbanization

EPA evaluated the population

, vehicle use characteristics

, and trends of the area as indicators of the probable location and magnitude of non

- point source emissions . These include ozone

- crea ting

emissions from on

- road and off

- road vehicles and engines, consumer products, residential fuel combustion, and consumer services. Areas of dense population or commercial development are an indicator of area source and mobile source NO x and VOC emissio ns. Rapid population or V ehicle

M iles T raveled ( VMT ) growth (see below) in a county on the urban perimeter signifies increasing integration with the core urban area, and indicates that it may be appropriate to include the area

associated with area source and mobile source emissions as part of the nonattainment area. Table 4

shows the population , population density, and population growth information for Sheboygan County and the adjacent counties

.

Table 4 . Population and Growth.

County State

Recommended

No nattainment? 2010 Population 2010 Population Density (1000 pop/sq mi) Absolute

C hange

in P opulation Population

% C hange (2000

- 2010)6 (2000

- 2010)

Sheboygan Coun t y No 115,507 0.22 2,762 +2%

Calumet County No 48,971 0.12 8,243 +2 0 %

Fond du Lac County No 101,633 0.13 4,250 + 4 %

Manitowoc County No 81,442 0.14

- 1483

- 2%

Ozaukee County No 86,395 0.37 3,867 + 5 %

Washington County No 131,887 0.30 13,928 + 1 2%

Source s : U.S. Census Bureau population estimates for 20 10 as of August 4, 2011

Population data show that the adjacent counties, as well as Sheboygan County, have relatively low populations and population densities. This implies that the population

- related NOx and VOC emissions in these counties are relatively low.

Traffic Data

EPA evaluat ed the total 2008 VMT and percent growth in VMT from 2002 to 2008 for Sheboygan

C ounty and the adjacent counties

. Table 5 shows this data.

Table 5 . Traffic Data

County State

Recommended

Nonattainment? 2008 VMT* (million miles) Percent

VMT

Growth (200 2

- 2008 )

Sheboygan County, WI No 1,018

- 10%

Calumet County No 371

- 13%

Fond du Lac County No 1,132 +46%

Manitowoc County No 807

- 27%

Ozaukee County No 962

- 7%

Washington County No 1,363 +31%
* MOBILE model VMTs are those inputs into the NEI versio n 1.5.

Traffic data show that the adjacent counties , as well as Sheboygan County, have rel atively low VMT

.



### Factor 3 : Meteorology ( W eather/ T

ransport P atterns)

EPA evaluate d available meteorological data to help determine how meteorological conditio ns, such as weather, transport patterns and stagnation conditions, would affect the fate and transport of precursor emissions contributing to ozone formation in the Sheboygan, WI MSA

. EPA examined the frequency

distribution of wind directions for summer (June

- August) by averaging National Weather Service

direction

- sorted wind directions for a 30 year period. Table 6 shows the summertime 30

- year averaged percentages of wind directions (winds blowing indo the subject county from the specified wind directio n sector).7 Table 6 . Averaged Summertime Wind Direction Percentages for the Sheboygan, WI MSA

Wind Direction Percentage

North

- Northeast 15.41%

East

- Northeast 6.91%

East

- Southeast 9.82%

South

- Southeast 10.96%

South

- Southwest 20.57%

West

- Southwest 15. 70%

West

- No r thwest 13.60%

North

- Northwest 7.02%

The wind direction data presented in Table 6 show that there is no “ predominant ” summertime wind

direction for Sheboygan County . The distribution is fairly even , with a slightly stronger southern

compon ent

.

The state provided wind direction data for hours from 2006 through 2008 when the 1

- hour ozone concentration was greater than or equal to 75 ppb . This data is presented in Table 7

.

Table 7 . Primary Wind Direction Percentages for Hours from 2006 T hrough 2008 When the 1

- hour Ozone Concentration Was Greater Than or Equal to 75ppb in the Sheboygan, WI MSA

Wind Direction Percentage

North 0%

North

- Northeast 0%

Northeast 0%

East

- Northeast 1.7%

East 0%

East

- Southeast 0.6%

Southeast 0.6%

South

- Sout heast 4.6 %

South 9.8%

South

- Southwest 76.4%

Southwest 5.7%

West

- Southwest 0.6%

West 0%

West

- No r thwest 0%

Northwest 0%

North

- Northwest 0%

Table 7 indicates that when considering wind direction data for hours from 2006 through 2008 when the

1

- ho ur ozone concentration was greater than or equal to 75 ppb in the Sheboygan, WI MSA, the primary

wind direction was from the south

- southwest 76.4% of the time , and the wind had a southerly component 98.3 % of the time. Thus winds that blow through Washingt on and Ozaukee counties and to a lesser extent Fond du Lac County may bring ozone or ozone precursors into the area on days when there are exceedances of the ozone standard at the violating monitor.8 

### Factor 4 : Geography/ T

opography ( M ountain R anges or O ther A ir B asin B oundaries)

The Sheboygan, WI area does not have any geographical or topographical barriers significantly limiting

air pollution transport within its air shed. Therefore, this factor did not play a significant role in this

evaluation

.



### Factor 5 : Jurisdictional B oundaries

J urisdictional boundaries are considered for the purposes of providing a clearly defined legal boundary

and to help identify the areas appropriate for carrying out the air quality planning and enforcement

functions fo r nonattainment areas. Examples of jurisdictional boundaries include existing/prior

nonattainment area boundarie s for ozone or other urban

- scale pollutants, count y lines , air district

boundaries , township boundarie s, areas covered by a metropolitan planni ng organization, state lines, and

Reservation boundarie s

.

The Sheboygan, WI area has previously established nonattainment boundaries associated with the 1

- hour and 1997 8

- hour ozone N AAQS. For both previous ozone NAAQS, the nonattainment area was compri sed of the entirety of Sheboygan County , which is synonymous with the Sheboygan, WI MSA

.



### Conclusion

The air quality monitor in Sheboygan County indicates a violation of the 2008 ozone NAAQS based on the 2010 design values

. Based on the assessment of f actor s described above

, EPA has concluded that Sheboygan County meets the CAA criteria for inclusion in the Sheboygan, WI nonattainment area. Th i s is the same area that comprised the Sheboygan, WI nonattainment area for the 1997 o zone NAAQS and

the same a rea that was designated as nonattainment under the 1

- hour NAAQS

. The other counties considered all had low emissions, population, and VMT. Available meteorological data shows that winds that blow through Washington and Ozaukee counties and to a lesser ex tent Fond du Lac County may bring ozone or ozone precursors into the area on days when there are exceedances of the ozone standard at the violating monitor. However, the low emissions, population, and VMT in these counties

leads to the conclusion that lon ger range transport is the significant contributor to violations of the standard in the Sheboygan, WI area. This conclusion is supported by modeling performed for the Cross

State Air Pollution Rule which shows the states of Illinois, Indiana, Wisconsin an d Michigan contributing 28.209 ppb, 11.244 ppb, 8.437 ppb, and 3.117 ppb, respectively, to ozone concentrations at the Sheboygan County monitoring site. In conclusion, EPA is only designating the county of Sheboygan as nonattainment for the Sheboygan, WI nonattainment area

.